AMAZON WEB SERVICES, INC., a Delaware Corporation,

Pursuant to Federal Rule of Civil Procedure 56, Plaintiff Acceleration Bay, LLC (“Acceleration Bay”), hereby moves the Court for (1) partial summary judgment that the Transit Gateway product satisfies the m-regular and incomplete limitations of the asserted claims, (2) summary judgment that the asserted claims are novel and non-obvious, and (3) summary judgment that there are no non-infringing alternatives available to Defendant Amazon Web Services, Inc. Pursuant to Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 597 (1993) and Rule 702 of the Federal Rules of Evidence, Acceleration Bay also moves to exclude the proposed (1) invalidity opinions of Mr. Greene, (2) non-infringing alternative opinions of Ms. Sultanik and Ms. Kindler, and (3) damages opinions of Ms. Kindler.

The grounds for these motions are fully set forth in Acceleration Bay’ Opening Brief and the supporting Declaration of Christina M. Finn, filed contemporaneously herewith, and upon the papers, records, and pleadings on file with the Court.

LR 7.1.1, Acceleration Bay certifies that the parties have met and conferred on the subjects of its Daubert Motions, but were unable to reach agreement.

Attorneys for Plaintiff Acceleration Bay, LLC